Port Med. Wellness, Inc. v. Conn. Gen. Life Ins. Co.

*158 INTRODUCTION

*835 Port Medical Wellness, Inc. (Port Medical) sued the International Longshore & Warehouse Union-Pacific Maritime Association Welfare Plan (Plan), its Board of Trustees (Board), and its former claims administrator, Connecticut General Life Insurance Company (Connecticut General), seeking *159 payment for health care services provided to persons eligible for benefits under the Plan. The trial court granted summary judgment in favor of all defendants. 1

State law causes of action seeking to recover unpaid benefits under a welfare benefit plan regulated under the Employee Retirement Income Security Act of 1974 (ERISA) ( 29 U.S.C. § 1001 et seq. ) are generally conflict preempted. We conclude that Port Medical's claims for breach of implied-in-fact contract, intentional misrepresentation and quantum meruit-each of which seeks payment for services covered under the Plan-are conflict preempted under section 514 of ERISA. Port Medical's two remaining claims-unfair competition ( Bus. & Prof. Code, § 17200 et seq. ) and intentional interference with prospective economic advantage-are not preempted because they are predicated on the theory that the Plan and Connecticut…